Category: Comment Letters

The MSBA submitted a comment letter to the CFPB in response to the RFI to assess adopted regulations and new rulemaking authorities.
Many of the MSBA members are classified as remittance transfer providers (“RTPs”) un ...

The MSBA recently submitted our Comment Letter to the CFPB on the RFI regarding Supervision. We appreciate that the Agency is providing an opportunity to gather input from all stakeholders to improve processes for our bu ...

The MSBA submitted a comment letter to the CFPB to explain that the obligations imposed on RTP’s through the Remittance Rule are in many ways redundant to rules already in place at the state level. Additionally, any consumer protection benefits they do afford are outweighed by the burdens imposed upon RTPs which are already sufficiently regulated by other federal agencies and the individual states. We therefore provide several recommendations for modifications to the Remittance Rule which will greatly reduce the burden and costs imposed on RTPs without sacrificing the Rule’s intended purpose of protecting consumers in the United States.

The MSBA submitted a letter to the OCC noting our questions and comments regarding their proposed National FinTech Charter. We commended the OCC for exploring new and innovative ways to increase payment innovation and reduce duplicative regulatory burdens. The concept of a Special Purpose National Bank Charter for Fintechs (to be referred to herein as the “Fintech Charter”) is one that has garnered a lot of attention and inquiries over the last few weeks.

Commonwealth’s De-Risking Meeting in London - IMTC

[…] Judie also mentioned that there were many in attendance that blamed the United States for the wave in de-risking in the world due to the Department of Justice’s enforcement actions that have been aimed at large banks. Banks were also being blamed as they imposed a “one size fits all” approach. The fact that US Banks are forcing correspondent banks in developing countries to close the bank accounts of local MSBs is also fueling the blame aimed at US institutions. Read more here. […]